2020 MIPS Promoting Interoperability Hardship Exception


CMS will allow for hardship exceptions for the Providing Interoperability (PI) performance category of MIPS in 2020. If an exception is granted the 25 MIPS points in the PI performance category will be reallocated to the quality performance category.  This article will summarize information related to hardship exception definitions, as available.  Note, certain clinician types that meet certain criteria have their PI category automatically reweighted to 0%.  These clinicians do not need to submit PI hardship exceptions.

To be considered for a PI category exception the practice or a designee must submit the application no later than December 31, 2020.  It may be beneficial to submit hardship exception application as soon as possible. If your application is accepted, you will be notified by email and you will not need to report data from the PI category for 2020. However, you will still have the option of reporting PI data if you elect to do so.  If you submit PI data despite receiving a hardship exception, you will be scored based on the data submitted, and the exception becomes void. CMS also states that if practices will be scored in the PI performance category if they attest to any data, such as selecting performance period dates or responding to attestation statements, during the submission period.

The following list represents examples of reasons specified by CMS as to why a practice may claim an exception for the PI category:

  1. Small Group Exception. This is applicable when:
    • The practice is reporting as a small group of 15 clinicians or as individuals, and
  2. The practice has experienced significant barriers to meeting the PI category requirements.
  3. The EHR that is being used by the practice has become decertified
  4. The practices experienced insufficient Internet connectivity
  5. The practice encountered extreme and uncontrollable circumstances, including but not limited to:
    • Disasters, natural and otherwise
    • Practice closure
    • Severe financial distress
    • Vendor issues
  6. The practice does not have control over the availability of Certified EHR Technology

Additional Information:

Small Group Exception:

Applicable to small practices that experience significant administrative, financial (or potentially other) barriers that prevent them from meeting the requirements of the Promoting Interoperability category of MIPS in the 2020 performance year.

Decertified EHR Technology Exception:

The PI hardship exception application contains the following statement: “In order to be approved for this hardship exception, the clinician(s) must attest to experiencing issues with the certification of the EHR product such as decertification.”

Insufficient Internet Connectivity Exception:

“In order to be approved for this hardship exception, the clinician(s) must attest to practicing in an area without sufficient internet access or facing insurmountable barriers to obtaining infrastructure (e.g. lack of broadband).”

Extreme and Uncontrollable Circumstances Exception-Disaster

In order to be approved for hardship exception, the clinician(s) must attest to facing Extreme and Uncontrollable Circumstances in the form of a natural disaster in which the EHR system was damaged or destroyed. Practices must attest to the time period the EHR system was unavailable, i.e., (MM/DD/YYYY) to (MM/DD/YYYY).

Extreme and Uncontrollable Circumstances Exception-Severe Financial Distress (Bankruptcy or Debt Restructuring)

Practices must attest attest that the clinician(s) faced extreme and uncontrollable circumstances in the form of severe financial distress resulting in hospital/clinic bankruptcy or restructuring of debt.  They must also attest to the time period that the EHR system was unavailable.

Extreme and Uncontrollable Circumstances Exception – Vendor Issues

The practice must attest that the clinician(s) faced extreme and uncontrollable circumstances in the form of vendor issues.  No further specific information is provided, however, the user is required to submit the period of time the EHR system was unavailable. Based on this it appears that is only applicable to situations where the EHR system becomes unavailable.

Lack of Control over the Availability of Certified EHR Technology Exception

The practice must attest to a lack of control over the availability of CEHRT in 1 or more practice locations where more than 50 percent of the patient encounters occurred (however, check the update 2020 application form for changes to this requirement).


  • As per CMS “Clinicians, groups and virtual groups should retain documentation of their circumstances supporting their application for their own records in the event they are selected by CMS for data validation or audit.”
  • Every office location/practice site covered by the practice’s TIN must experience the hardship for the practice to qualify for the exception.
  • Practices that switch vendors during the reporting period may claim the exception.

In order to apply for an exception for the promoting interoperability category of MIPS please loginto your HARP account via the QPP website: Promoting Interoperability Hardship Exception Application

Please contact us at info@apollohit.com for questions or feedback.

CMS will allow for exceptions for all categories of the Quality Payment Program if there is a natural disaster or a public health emergency.  Please also see the 2020 Extreme and Uncontrollable Hardship Exceptions page for more information.


Disclaimer: the information on this website may contain interpretations of guidance provided by CMS on the above topics. Please review the official documents for specific guidance.  Please also note that the criteria above may change.  Please review the exception application closely for additional requirements before submitting.


  • 2020 Quality Payment Program Exception Applications Fact Sheet
  • CMS Quality Payment Program website
  • Correspondence with CMS representatives


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